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Zorluk: OrtaAnti-Money Laundering (AML), KYC, and Sanctions Compliance

During a routine onboarding check, a broker-dealer discovers that a prospective customer's name matches an entry on the Specially Designated Nationals and Blocked Persons (SDN) List maintained by the Office of Foreign Assets Control (OFAC). Which of the following actions must the firm take regarding the account and assets?

  1. Immediately block (freeze) the account assets and report the match to OFAC within 10 business days.Cevap
  2. B
    Allow normal account operations but file a Suspicious Activity Report (SAR) within 30 calendar days.
  3. C
    File a Currency Transaction Report (CTR) with FinCEN within 15 calendar days if the account holds cash.
  4. D
    Decline the account opening request and immediately return all deposited funds to the applicant.

Cevap

Immediately block (freeze) the account assets and report the match to OFAC within 10 business days.
When a firm confirms a match against the OFAC Specially Designated Nationals (SDN) List, federal law requires the firm to immediately block (freeze) the customer's account and assets and submit a report to OFAC within 10 business days. Returning the funds or allowing transactions violates U.S. sanctions regulations.

Adım Adım Çözüm

1
Identify the compliance mandate governing SDN List matches.
OFAC regulations require U.S. financial institutions to prohibit transactions with individuals or entities on the SDN list.
Trading or transferring assets involving blocked parties is illegal under U.S. federal sanctions law.
2
Determine the required action regarding customer funds when a confirmed match occurs.
The firm must freeze (block) the assets in place immediately so they cannot be withdrawn or transferred.
Returning assets to a sanctioned individual violates federal regulations.
3
Identify the reporting timeline and regulatory agency.
The firm must report the blocked assets to OFAC within 10 business days.
Federal rules mandate prompt notification to OFAC upon blocking property.

Anahtar Kavram

OFAC Sanctions Compliance and SDN List Obligations
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